The proposed 2019/2020 ESG Applications will be divided into three parts: General Threshold Criteria, Uniform Selection Criteria, and Program Participant Services.

A. General Threshold Criteria. This Application section would not be scored, but all of the criteria must be met or the Application will not be considered for funding. Threshold criteria include, but is not limited to, evidence of Data Universal Numbering System number; commitment of 100% match or submission of a match waiver; evidence from the CoC that the Applicant consulted with the CoC and the CoC Lead Agency agrees that the Application meets CoC priorities; and local government approval of emergency shelter activities, as applicable.

C. Program Participant Services. This Application section is scored and includes, but not is not limited to:

i. collaboration with other homeless services organizations, as determined by the CoC Lead Agency; ii. providing up to 105% matching funds; iii. setting a target to serve persons with special needs; iv. number of services provided (i.e., case management, transportation, etc.); v. years of experience providing Program Participant service; vi. performance target to transition Program Participants to temporary/transitional housing, as applicable; vii. performance target to exit Program Participants to permanent housing, as applicable; and viii. performance target for Program Participants to maintain housing for three or more months after exit, as applicable.

Applicants will not be able to subgrant funding nor submit Applications with more than one organization to be awarded funds. This is a change from the 2017/2018 ESG Application process in which Applicants could submit collaborative Applications that consisted of services provided by several different organizations. In the proposed draft rule, collaboration with other organizations can occur locally and be determined by the CoC Lead Agency, but is not handled through collaborative application submissions for ESG.

All performance targets will be based on percentages of Program Participants served, and not whole numbers of persons served. This is different than the 2017/2018 ESG NOFA in which a few performance targets were based on whole numbers of persons served.

Applicants will receive points for targeting to serve a percentage of Program Participants with special needs to create a point structure for Applicants to serve Program Participants that may be harder to house. This is similar to the 2017/2018 ESG NOFA in which points were awarded for serving persons with high barriers to housing. In 2019/2020, Program Participants with special needs includes more persons than the previous Application rounds: persons experiencing chronic homelessness; colonia residents; persons with HIV/AIDS; persons exiting a correctional program/correctional institution; persons exiting a health care facility/mental health facility; persons with a substance use disorder, persons with mental illness; unaccompanied children (under 18 years); unaccompanied youth (18-24 years); veterans; victims of domestic violence; and youth aging out of foster car

Is the CoC Lead Agency's determination of collaboration an accurate measurement? Is there another way to determine the extent to which an ESG Applicant has collaborated locally?

Should all performance targets be based on percentages, or should some performance targets include whole numbers of persons served?

Are there Program Participants with special needs that should or should not be included?

We cover cities from Dallas to Amarillo to Midland-Odessa and San Angelo. Is there a category that will allow us to apply for funds that may be used to help eligible ESG applicants in multiple cities with one project? Are we confined to operate just one ESG project in one metropolitan area? What about the enormous stretches of rural territory - are they also covered?

Here is some clarification to the questions from Sam Prince: The regions for the ESG Applications would continue to be the Continuum of Care (CoC) regions, which is not a change from the 2017/2018 ESG Application cycle. Applicants would be able to apply for ESG in more than one CoC region. The stretches of rural territory are part of the Texas Balance of State CoC. We have attached a map of the CoC regions for reference. TexasCoC_Map.pdf

The collaborative approach created under prior ESG grants has resulted in a real continuum of care to homeless clients in our area. Because of shared services, the organizations who have formed close partnerships have significantly reduced the time clients spend in a homeless state—from emergency or transitional shelter or the streets to rapid rehousing. It is disturbing to think that those close partnerships will now be parted and, worse, may be forced to compete against each other for ESG funds. We hope you will find a way to honor collaboration in the proposed application process—to build on successes the Department has made in addressing the emergency solutions to homelessness rather than to go back to an era where organizations competed for scarce funds. We would like you to consider giving this year’s approach a chance—programs designed as collaborations with individual contracts with the Department. I believe this was done a few years ago and, for us, it was successful.

1. Is the CoC Lead Agency's determination of collaboration an accurate measurement? Is there another way to determine the extent to which an ESG Applicant has collaborated locally?

It would be difficult to quantify. This depends on the strength of the CoC, the amount of resources, and number of related homeless services providers in a community. Therefore it is not an equitable measure. It is also heavily dependent on the definition of collaboration. Not all definitions are equal. Another way would be to still allow collaborative applications.

2. Should all performance targets be based on percentages, or should some performance targets include whole numbers of persons served?Most if not all targets should be. It allows for more equitable comparisons across the regions and even within regions. There is no cost allocation comparison. That might be a way to demonstrate cost effectiveness by measuring cost per client to help balance were a program serving 10 clients might have better outcomes over a much larger program but cost would be higher.

3. Are there Program Participants with special needs that should or should not be included?Since it is proposed as a scored item, as long as this is clearly defined and limited to HUD identified special groups it should be appropriate but a list to react to might be more helpful to comment on.

Is the CoC Lead Agency's determination of collaboration an accurate measurement? Is there another way to determine the extent to which an ESG Applicant has collaborated locally?

We would like to see stronger operational definition of what participation and acceptance looks like because each Lead Agency has created their own structure. Possibly this could mean that the CoC governing body approves the collaboration. How will the CoC document such approval? For example, our CoC's Lead Agency posts formal meetings minutes on their website to document such decisions.

Should all performance targets be based on percentages, or should some performance targets include whole numbers of persons served?

Percentage will help create a more equitable comparison across projects. However, if a smaller project has a negative outcome (and if funding is restricted per Topic #1, there will be smaller projects) – percentages will impact them more heavily. How would TDHCA consider smaller projects' performance when reviewing and ranking projects?

3.Are there Program Participants with special needs that should or should not be included?

Please keep all the listed sub-populations. TDHCA and applicants should consider local PIT count data to ensure that population being served by projects mirror the community.

Under the proposed rule, CoC lead agencies would be asked to determine how they would strongly recommend, recommend, or approve each Program Participant service for each Applicant. CoC lead agencies would have discretion as to the documentation process for the recommendation.

Using percentages of outcomes instead of whole numbers of persons who achieved outcomes attempts to address the comparison of small and large projects. The Department would be open to suggestions for other ways to consider smaller projects' performance when reviewing and ranking projects.

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